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HomeMy WebLinkAbout87-0086~ IN THE COURT OF GUkalviu~',a rk~ ~ OF CUMBERLAND COUNTY STATE OF ~ PENNA. BARBARA A. BARRICK, ............................... Plaintiff Versus .JQH~._E ..... BARR_ICK. ............................................ Defendant ~ 0 ...... 8.6 .............. ..ez~xz..19 87 DECREE IN DIVORCE AND NOW ....... ~,/~~ ..... / ..... 19. s.7..., it is ordered and decreed that .....B.A.R.B.A..Rk A,. t~.-qggI.C.K ........................ plaintiff, and .............~.o~N..F... BAR~ZZCX .......................... defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; h3ON. E .................................................. BARBARA A. BARRICK, Plaintiff Ve JOHN F. BARRICK, Defendant IN THE COURT OF COMMON PLEAS 0F CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 86 CIVIL 1987 IN DIVORCE PRAECIPE TO TRANSMIT. RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree. 1. Ground for divorce: irretrievable breakdown under Section 201 (c). 2. Date and manner of service of the complaint: January 15, 1987, Certified Mail, ,5{estricted Delivery", Return Receipt No. P 268 605 805. 3. (a) Date of execution of the affidavit of consent required by Section 201 (c) of the Divorce Code: by the plaintiff - /~J~'~ ~ , 1987 by the defendant - /~~V~ , 1987 4. Related claims pending: None Aibert H. Mas±ana Attorney for Plaintiff COUNTY Auo Z5 I l~ I'M IN THE COURT OF COMMON PI,VAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVI~ ACTION - LAW CIVIL 1987 IN DIVORCE BARBARA A. BARRICK, Plaintiff V. JOHN F. BARRICK, Defendant COMPLAINT UNDER SECTION 201(c) OF THE DIVORCE CODE ALBERT H. MASLAND Attorney At Law 7 EAST HIGH STREET ,, CARLISLE, PENNSYLVANIA 17013 (71 7) 249-6033 BARBARA A. BARRICK, Plaintiff JOHN F. BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ciVIL 19s7 IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, First Floor, Cumberland County Court House, Carlisle, Pennsylvania. 17013. IF YOU DO NOT FILE FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Third Floor Cumberland County Court House Carlisle, Pennsylvania, 17013 (717) 249-1133 BARBARA A. BARRICK, Plaintiff JOHN F. BARRICK, Def end ant IN THE COURT 0P COMMON PLEAS 0P CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ~ CIVIL 1987 IN DIVORCE COMPLAINT UNDER SECTION 201 (c) 0F THE DIVORCE CODE AND NOW comes Barbara A. Barrick, the above-named plaintiff, and by her attorney, Albert H. Masland, Esquire, files this complaint in divorce against the defendant, John F. Barrick, upon the cause of action hereinafter set forth: The name o£ the plaintiff is Barbara. A. Ba. rrick, and the name of the defendant is John ~. Barrick. The plaintiff is a resident of the Borough of Carlisle, Cumberland County, Pennsylvania; she currently resides at 1860 Aeronca Street, Carlisle, Pennsylvania, 17013. The last known residence and present whereabouts of the defendant is 1860 Aeronca Street, Carlisle, Pennsylvania, 17013. The parties have resided in the Commonwealth of Pennsylvania for at least six months immediately previous to the commencement of this action in divorce. The plaintiff and defendant were married on June ~0, 1957 in New Kingston, Pennsylvania. ?ursuant to the Divorce Code, Section 201(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. The plaintiff avers that neither party to this action had ever previously instituted an action in divorce or annulment of this marriage in this court or in any other court· The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request thst the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage betwee~ the parties. Attorney for Plaintiff 7 East High Street Carlisle, PA !701~ (717) 249-6033 I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Barbara A. Barrick Plaintiff BARBARA A. BARRICK, Plaintiff JOHN F. BARRICK, Defendant IN THE COURT 0F COMMON PLEAS 0F CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 86 CIVIL 1987 IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT COMM0~¢EALTH OF PENNSYLVANIA : : SS: COUNTY 0Y CUMBERLAND : AND NOW, Albert H. Masland, Esquire, being duly sworn according to law, does depose and state: That he is a competent adult and attorney for Barbara A. Barrick, plaintiff in the captioned action. e That he served the defendant, John F. Barrick, on January 15, 1987, by sending a certified copy of the Complaint to him, by certified mail, on January 14, 1987, marked "restricted delivery", with a return receipt requested, and being receipt for certified mail number P 268 605 805, addressed to John F. Barrick, 1860 Aeronca Street, Carlisle, PA 17013. That the said receipt for certified mai]_ was personally signed by the defendant, John F. Barrick , as evidenced by a copy of the return receipt which is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. of 4904, relating to unsworn falsification to authorities. Attorney for Plaintiff BARBARA A. BARRICK, Plaintiff Ve JOHN F. BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 86 CIVIL 1987 IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT A complaint in divorce under Section 201(c) Code was filed on January 14, 1987. of the Divorce The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. I consent to the entry of a final decree in divorce. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct· I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: BARBARA -A. BARRICK BARBARA A. BARRICK, P 1 ai nt iff Ve JOHN F. BARRICK, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 86 CIVIL 1987 : : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A complaint in divorce under Section 201(c) of the Divorce Code was filed on January 14, 1987. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. I consent to the entry of a final decree in divorce. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. F. BARRICK OF FHE